Treatment of COD income under secs. 704 and 752. (cancellation of debt): An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on May 1, 1993. The length of the article is 1543 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: IRS Revenue Ruling 92-97 establishes that cash distributions from partnerships which reduce a partner's liability and occur as part of a cancellation of debt (COD) arrangement will be recognized at the end of the partnership's tax year. This is a beneficial ruling because the COD can be used to offset the cash distribution for purposes of recognizing gain or loss. This ruling regards the cash distribution rules under IRC 752(b) and the economic effect rules under IRC 704.

Citation Details
Title: Treatment of COD income under secs. 704 and 752. (cancellation of debt)
Author: Richard N. Kipper
Publication:The Tax Adviser (Magazine/Journal)
Date: May 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n5 Page: 294(3)

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